Facts:

The case involves Malan Brothers Watchman Agency as the petitioner and Magdaleno Conanan along with the Workmen's Compensation Commission as the respondents. The events leading to the case began on November 6, 1959, when Magdaleno Conanan, a security guard employed by Malan Brothers Watchman Agency, sustained injuries to his left leg due to an accidental discharge of his service pistol while on duty at the Manila Bay Hosiery Mills, Inc. in Bacood, Sta. Mesa, Manila. Following the incident, Conanan filed a claim for compensation on January 6, 1960, with the Regional Office No. 4 of the Department of Labor under Act No. 3428, as amended. The claim was formally communicated to Malan Brothers on February 5, 1960, along with necessary forms for the agency to complete. However, these forms were returned unclaimed. On March 29, 1960, the claim and forms were resent via registered mail to the agency's new address, where they were acknowledged by the manager, Fabio Malan, on A...

Facts:

Parties Involved:

• Petitioner: Malan Brothers Watchman Agency
• Respondents: Magdaleno Conanan and the Workmen's Compensation Commission

Nature of the Case:

• Appeal by certiorari from the order and resolution of the Workmen's Compensation Commission (WCC) in WCC-R04-Case No. 62349.

Background of the Case:

1. Employment Details:

   • Magdaleno Conanan was employed as a security guard by Malan Brothers Watchman Agency, a licensed agency recruiting security personnel.

2. Incident Leading to the Claim:

   • On November 6, 1959, while on duty at Manila Bay Hosiery Mills, Inc., Conanan sustained injuries to his left leg when his service pistol accidentally discharged.

3. Filing of the Claim:

   • On January 6, 1960, Conanan filed a compensation claim under Act No. 3428 (Workmen's Compensation Act) with Regional Office No. 4 of the Department of Labor.
   • The claim and required forms (Employer's Report of Accident, Physician's Report, etc.) were sent to Malan Brothers Watchman Agency on February 5, 1960, but were returned unclaimed.
   • A second attempt was made on March 29, 1960, via registered mail to the agency's new address. The manager, Fabio Malan, acknowledged receipt on April 4, 1960.

4. Controversion of the Claim:

   • On October 3, 1960, the agency submitted the completed forms, contesting the claim but admitting it had paid Conanan P350.00 as "voluntary help."
   • The controversion was filed beyond the statutory period under Section 45 of Act No. 3428.

5. Award by the Regional Administrator:

   • On October 12, 1960, the Regional Administrator awarded Conanan P3,371.46, as the claim was deemed uncontroverted.
   • Notice of the award was sent to the agency on October 26, 1960, but it refused to claim the notice despite two registry notices.

6. Motions for Reconsideration:

   • On February 3, 1961, the agency filed a motion for reconsideration, arguing the award was granted without a hearing.
   • The motion was denied on June 2, 1961, and a second motion was denied on June 16, 1961.

7. Appeal to the Workmen's Compensation Commission:

   • The agency appealed to the WCC, which dismissed the appeal on September 18, 1961.
   • A motion for reconsideration was also denied, prompting the present appeal.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Finality of the Award:

   • Under Section 45 of Act No. 3428, the petitioner was required to controvert the claim within the statutory period. Its failure to do so rendered the claim uncontroverted, making the award final and executory.
   • The petitioner's motion for reconsideration was filed more than 60 days after receiving notice of the award, making it untimely.

2. Validity of the Award Without a Hearing:

   • For uncontroverted claims, the Workmen's Compensation Act does not require a formal hearing. The Regional Administrator may decide based on the claim and supporting evidence.
   • The petitioner's argument that the award was void for lack of a hearing was without merit, as the law explicitly allows decisions on uncontroverted claims without a hearing.

3. No Excusable Delay in Controversion:

   • The petitioner had knowledge of the accident and the claim but delayed filing the controversion for six months without justification.

Conclusion:

The Supreme Court upheld the Workmen's Compensation Commission's decision, affirming the award in favor of Magdaleno Conanan and dismissing the petitioner's appeal. Costs were imposed on the petitioner.